Course 712. Safety Supervision and Leadership

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1 Safety Supervision and Leadership

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3 OSHAcademy Course 712 Study Guide Safety Supervision and Leadership Copyright 2017 Geigle Safety Group, Inc. No portion of this text may be reprinted for other than personal use. Any commercial use of this document is strictly forbidden. Contact OSHAcademy to arrange for use as a training document. This study guide is designed to be reviewed off-line as a tool for preparation to successfully complete OSHAcademy Course 712. We hope you enjoy the course and if you have any questions, feel free to or call: OSHAcademy NW Greenbrier Parkway, Suite 230 Beaverton, Oregon instructor@oshatrain.org Disclaimer This document does not constitute legal advice. Consult with your own company counsel for advice on compliance with all applicable state and federal regulations. Neither Geigle Safety Group, Inc., nor any of its employees, subcontractors, consultants, committees, or other assignees make any warranty or representation, either express or implied, with respect to the accuracy, completeness, or usefulness of the information contained herein, or assume any liability or responsibility for any use, or the results of such use, of any information or process disclosed in this publication. GEIGLE SAFETY GROUP, INC., DISCLAIMS ALL OTHER WARRANTIES EXPRESS OR IMPLIED INCLUDING, WITHOUT LIMITATION, ANY WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. Taking actions suggested in this document does not guarantee that an employer, employee, operator or contractor will be in compliance with applicable regulations. Ultimately every company is responsible for determining the applicability of the information in this document to its own operations. Each employer s safety management system will be different. Mapping safety and environmental management policies, procedures, or operations using this document does not guarantee compliance regulatory requirements. Revised: October 31, 2017

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5 Contents Course Introduction... 1 Supervisors Are the Key... 1 Module 1: Overview of Employer Responsibilities... 2 Introduction... 2 Safety is Smart business!... 2 The Importance of the Supervisor... 2 What the Law Says... 2 Employer Responsibilities... 3 Employee Responsibilities... 6 Discrimination against Employees Who Exercise Their Safety and Health Rights... 7 Module 1 Quiz... 8 Module 2: Identifying Hazards Introduction The Five Workplace Hazard Categories Supervisor Role The Walk-around Safety Inspection The Person Conducting the Inspections How to Build an Effective Safety Inspection Checklist Make Everyone an Inspector The Job Hazard Analysis (JHA) Why the JHA? Investigating Incidents and Accidents... 15

6 The Incident/Accident Investigation Process Get To The Root Causes Scenario Module 2 Quiz Module 3: Correcting Hazards Introduction The Hierarchy of Hazard Control Strategies Controlling Hazards Controlling Behaviors Elimination Examples of elimination controls include: Substitution Engineering Controls Administrative Controls Personal Protective Equipment (PPE) Module 3 Quiz Module 4: Providing Safety Training Introduction Why Employees Don't Comply with Safety Rules Responsibilities Should Be Given to Supervisors Supervisors Should Be Trainers When Safety Training Should Occur A Case for Initial Orientation Training at Safety Meetings... 30

7 Common Sense or Individual Good Sense Every Culture is Different Training Topics Important Guidelines About Safety Training Model Training Strategy Module 4 Quiz Module 5: Providing Safety Supervision Introduction The Key to Safety Supervision is Super Vision Delegate Scenario Leaders Know How to Use Recognition Withholding Injury Reports Management-Level Behaviors Safety Leadership Module 5 Quiz Module 6: Ensuring Accountability Introduction Accountability Accountable Systems Element 1: Established Standards of Performance Element 2: Resources to Achieve those Standards Element 3: A System of Measurement Element 4: Appropriate Application of Effective Consequences... 48

8 Very Important Questions Two Sides to the Accountability Coin Element 5: A Process to Evaluate the Accountability System Module 7: Creating a Culture of Consequences Introduction The Four Categories of Consequences There Are Thanks and Then There Are Thanks Criteria for Effective Recognition Module 7 Quiz Module 8: Safety Leadership Introduction What Works: Tough-Caring Leadership What Doesn't Work: Tough-Coercive Leadership What Doesn't Work: Tough-Controlling Leadership What Leadership is Not The Five Levels of Leadership Workplace Culture Corporate Culture and Personality Management + Leadership = Culture What's Your Leadership Style? What do your scores mean?... 73

9 Course Introduction Supervisors Are the Key The supervisor is the one person who can take immediate, direct action to make sure that his or her work area is safe and healthful for all employees. Russell DeReamer, author of Modern Safety Practices, considers the supervisor the only person who can control employees, machines, and working conditions on a daily, full-time basis. In his text, Occupational Safety and Health Management, Thomas Anton relates that the supervisor bears the greatest responsibility and accountability for implementing the safety and health program because it is he or she who works most directly with the employee. It is important that the supervisor understands and applies successful management and leadership principles to safety and health to make sure employees enjoy an injury- and illness-free work environment. This course introduces you to key elements that help the supervisor demonstrate "5-STARS" supervision and leadership within the safety and health function. The key 5-STARS of safety supervision and leadership are: Supervision - overseeing work activities to make sure employees are safe. Training - conducting safety education and training. Accountability - insisting everyone complies with company safety policies and rules. Resources - providing physical resources (tools, equipment, materials, etc.) so employees can work safely. Support - creating a supportive, psychosocial work environment (schedules, workloads, recognition, etc.) so employees do not work under undue stress. Supervisors can demonstrate leadership by directly providing employees the resources, motivation, priorities, and accountability for ensuring their safety and health. Enlightened supervisors understand the value in creating and fostering a strong safety culture within their department. Safety is elevated so that it is a value as opposed to something that must be done or accomplished. Integrating safety and health concerns into the everyday supervision allows for a proactive approach to accident prevention and demonstrates the importance of working safely. Copyright 2017 Geigle Safety Group, Inc. Page 1 of 75

10 Module 1: Overview of Employer Responsibilities Introduction As an "agent of the employer" the supervisor assumes the responsibilities of the employer to the degree he or she has been given authority. This first module will introduce you to some of the basic employer responsibilities to OSHA law, and the obligations the employer and employees have to each other. Fulfilling these obligations is a function of competent management and leadership: the theme throughout the entire course. Safety is Smart Business! Although we're discussing what the legal obligations the employer has in this module, it's important not to lose sight of the fact that "doing safety" to primarily avoid OSHA violations and penalties is probably the least effective safety management approach. Employers who understand the long term financial and cultural benefits derived from world-class safety management and leadership will be more likely to develop a proactive safety and health system that not only meets OSHA requirements, but far exceeds them. You can find out more about developing effective safety systems in Course 700. The Importance of the Supervisor The supervisor is the person who can take immediate, direct action to make sure that his or her work area is safe and healthful for all employees. In his text, Occupational Safety and Health Management, Thomas Anton relates that the supervisor bears the greatest responsibility and accountability for implementing the safety and health program because it is he or she who works most directly with the employee. It is important that the supervisor understands and applies successful management and leadership principles to make sure their employees enjoy an injury- and illness-free work environment. Management may be thought of as applying organizational skills, while leadership involves effective human relations skills. What the Law Says As detailed in the Section 5 (The General Duty Clause) of the OSHA Act of 1970, the employer is assigned responsibility and held accountable to maintain a safe and healthful workplace. Copyright 2017 Geigle Safety Group, Inc. Page 2 of 75

11 Excerpt: Public Law , 91st Congress, S. 2193, December 29, 1970: An Act To assure safe and healthful working conditions for working men and women; by authorizing enforcement of the standards developed under the Act; by assisting and encouraging the States in their efforts to assure safe and healthful working conditions; by providing for research, information, education and training in the field of occupational safety and health; and for other purposes. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, That this Act may be cited as the 'Occupational Safety and Health Act of 1970'. Section 5 (a) Each Employer - (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees; (2) shall comply with occupational safety and health standards promulgated under this act. (b) Each employer shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct. Employer Responsibilities As you can see, employers have clearly defined responsibilities under the Occupational Safety and Health Act of The following list is an expansion on those basic responsibilities that are stated throughout the OSHA standards. Provide a workplace free from recognized hazards. A recognized hazard may be thought to be one that is known by or should be known by the employer, such as conditions and practices generally known to be hazardous in an industry. Ultimately, fulfilling this Copyright 2017 Geigle Safety Group, Inc. Page 3 of 75

12 requirement is a function of sound management and leadership. We'll be addressing effective management throughout the course, and leadership more specifically in Module 8. Examine workplace conditions to make sure they conform to applicable OSHA standards. Workplace conditions can be thought of as things or states of being. Hazardous conditions include tools, equipment, workstations, materials, facilities, environments, and people. Employees who, for any reason, are not capable of working safely should be considered hazardous conditions in the workplace. Identifying hazards will be covered in Module 2. Minimize or reduce hazards. OSHA expects the employer to first consider engineering controls to eliminate or reduce hazards. Work practice, administrative controls, and personal protective equipment are also strategies used to minimize or reduce hazards. We'll be addressing this important responsibility in Module 3. Make sure employees have and use safe tools and equipment and properly maintain this equipment. How does the employer "make sure" this responsibility is fulfilled? Adequate supervision means identifying and correcting hazardous conditions and unsafe work practices before they result in injuries. Successfully meeting this responsibility will be covered in Module 4. Use color codes, posters, labels, or signs to warn employees of potential hazards. Remember, warnings do not prevent exposure to hazards. Make sure warnings describe the consequences of exposure or behavior. Establish or update operating procedures. Is OSHA talking about a comprehensive safety program? Although it is not yet required by OSHA standards, it's smart business to develop a comprehensive written plan that addresses commitment, involvement, identification, control, analysis, and evaluation activities. Typically, first-line supervisors are not involved in developing comprehensive safety plans unless they are members of a safety committee. Communicate safety policies, procedures, and rules. This requirement is necessary so that employees follow safety and health requirements. The supervisor is a key player in communicating safety expectations. Although the safety committee and safety Copyright 2017 Geigle Safety Group, Inc. Page 4 of 75

13 coordinator may provide help in fulfilling this responsibility, do not assume it's solely their job. Effective safety communications will be addressed in Module 4. Provide medical examinations and training when required by OSHA standards. Respiratory protection, bloodborne pathogens, and other rules may require examinations. Provide adequate safety education and training. Of course, any exposure to hazards requires training. Safety education at all levels of the organization is critical to a successful safety culture. More on this topic in Module 5. Report fatalities and catastrophes to the nearest OSHA office within 8 hours. This requirement includes any fatal accident or one that results in the hospitalization of three or more employees. If you work in a "state plan" state, your OSHA laws may include additional reporting requirements. Keep records of work-related injuries and illnesses. Provide employees, former employees, and their representatives access to the OSHA Form 300 at a reasonable time and in a reasonable manner. Post the OSHA Form 300-A summary in an area that is accessible to employees no later than February 1 of the year following the year covered by the records and keep the posting in place until April 30 of that same year. Provide access to employee medical records and exposure records. Access should be provided to affected employees or their authorized representatives. Not discriminate against employees who exercise their rights under the Act. Employees have a legal right to communicate with OSHA. No employee should be subject to restraint, interference, coercion, discrimination, or reprisal for filing a report of an unsafe or unhealthful working condition. More on this later in the module. Post OSHA citations at or near the work area involved. Each citation must remain posted until the violation has been corrected, or for three working days, whichever is longer. Post abatement verification documents or tags. Correct cited violations by the deadline set by OSHA citation and submit required abatement verification documentation. Of course, these are not all of the employer responsibilities, but this summary does present those general responsibilities each employer has to both the law and their employees. The list Copyright 2017 Geigle Safety Group, Inc. Page 5 of 75

14 above reflects the fact that the employer has control of work and workplace conditions. Tied to that control is accountability. On the other hand, what general responsibilities do employees have to their employer? Employee Responsibilities Although OSHA does not cite employees for violations of their responsibilities, each employee must comply with all occupational safety and health standards and all rules, regulations, and orders issued under the Act that are applicable. Employee compliance is not likely unless the employer holds its employees accountable. Think of it this way: the employer is held accountable to OSHA standards, while the employee is held accountable to the employer standards. One effective strategy for communicating this "chain of command" for accountability is for the employer to use language stressing that employees comply with the "company's safety rules" rather than the OSHA rules. Instead of having an "OSHA Manual," construct an "XYZ, Inc. Safety Manual." Following this strategy to communicate responsibilities is important for a couple of reasons: The employer communicates the message that they are doing safety because the want to out of concern for their safety, not because they have to in order to comply with the law. Employees at all levels should clearly understand the "chain of command" for accountability in the workplace. According to OSHA law, employees should do the following: Follow all lawful OSHA and employer safety policies and rules. Report hazardous conditions to the supervisor. Immediately report any job-related injury or illness to the employer. Seek proper treatment if injury or illness occurs. Copyright 2017 Geigle Safety Group, Inc. Page 6 of 75

15 Discrimination against Employees Who Exercise Their Safety and Health Rights Workers have the right to complain to OSHA and seek an OSHA inspection. Section 11(c) of the Occupational Safety and Health Act of 1970 allows OSHA to investigate employee complaints of employer discrimination against those who are involved in safety and health activities. OSHA is also responsible for enforcing whistleblower protection under ten other laws. OSHA Area Office staff can explain the protections under these laws and the deadlines for filing complaints. Workers in the 23 states operating OSHA-approved State Plans may file complaints of employer discrimination with the state plan as well. State and local government workers in these states (and two others with public employee only state plans) may file complaints of employer discrimination with the state. Some examples of discrimination are firing, demotion, transfer, layoff, losing opportunity for overtime or promotion, exclusion from normal overtime work, assignment to an undesirable shift, denial of benefits such as sick leave or vacation time, blacklisting with other employers, taking away company housing, damaging credit at banks or credit unions and reducing pay or hours. Refusing to do a job because of potentially unsafe workplace conditions is not ordinarily an employee right under the OSHA Act. (Your union contract or state law may, however, give you this right, but OSHA cannot enforce it.) Refusing to work may result in disciplinary action by your employer. However, employees have the right to refuse to do a job if they believe in good faith that they are exposed to an imminent danger. "Good faith" means that even if an imminent danger is not found to exist, the worker had reasonable grounds to believe that it did exist. Most discrimination complaints fall under the OSHA Act of 1970 that gives the employee only 30 days to report acts of discrimination. OSHA conducts an in-depth interview with each complainant to determine the need for an investigation. If evidence supports the worker's claim of discrimination, OSHA will ask the employer to restore the worker's job, earnings and benefits. If the employer objects, OSHA may take the employer to court to seek relief for the worker. Copyright 2017 Geigle Safety Group, Inc. Page 7 of 75

16 Module 1 Quiz Use this quiz to self-check your understanding of the module content. You can also go online and take this quiz within the module. The online quiz provides the correct answer once submitted. 1. According to Thomas Anton, this position bears the greatest responsibility and accountability for implementing the safety and health program policies and procedures? a. Owner b. Manager c. Supervisor d. Employee 2. What government "Act" assigns responsibility to maintain a safe and healthful workplace to the employer? a. The DOL Act of 1973 b. The BLS/OSHA Act c. The OSHA Act of 1970 d. The EPA Act of The "Act" in question 2 states that the employer is to provide a workplace free from that are causing or are likely to cause death or serious physical harm. a. hazardous conditions b. unsafe behaviors c. recognized hazards d. unknown conditions Copyright 2017 Geigle Safety Group, Inc. Page 8 of 75

17 4. Employees who, for any reason, are not capable of working safely should be considered. a. hazardous conditions b. unsafe behaviors c. dangerous situations d. unknown conditions 5. All the following are mandated employer responsibilities, except. a. provide personal protective equipment b. conduct random drug tests c. conduct safety training d. enforce compliance with safety rules Copyright 2017 Geigle Safety Group, Inc. Page 9 of 75

18 Module 2: Identifying Hazards Introduction Since 1970, workplace fatalities have been reduced by half. Occupational injury and illness rates have been declining for the past six years, dropping in 1998 to the lowest level on record. But there is much more to do. Nearly 50 American workers are injured every minute of the 40-hour work week and almost 17 die each day. Federal and state OSHA programs have only about 2,500 inspectors to cover 100 million workers at six million worksites. Workers must play an active role in spotting workplace hazards and asking their employers to correct them. In this module, we'll take a look at the five areas within which all workplace hazards exist. Additionally, we'll discuss the inspection and job hazard analysis processes that are two important proactive hazard identification processes. Finally, we'll examine the incident and accident investigation process and how it can effectively identify and help to eliminate hazards. The Five Workplace Hazard Categories To help identify workplace hazards, it's useful to categorize them into easy-to-remember categories. The first three categories represent hazardous conditions. According to SAIF Corporation, a major workers compensation insurer in Oregon, conditions directly account for only 3% of all workplace accidents. The fourth category describes employee behaviors in the workplace that may contribute or cause as much as 95% of all workplace accidents. All five categories represent the surface symptoms of underlying root causes or safety management system weaknesses. Take a look at the accident weed to get a better idea about the relationship between surface symptoms and root causes for accidents. To remember the five hazard areas, don t forget the acronym MEEPS: Materials, Equipment, Environment, People, and System. Let's review these five categories. Materials: liquids, solids and gases that can be hazardous to employees. Liquid and solid chemicals (such as acids, bases, solvents, explosives, etc.) can produce harmful effects. Copyright 2017 Geigle Safety Group, Inc. Page 10 of 75

19 Raw materials (solids like metal, wood, and plastic) used to manufacture products are usually bought in large quantities and can cause injuries or fatalities in many ways. Gases, like hydrogen sulfide and methane, may be extremely hazardous if leaked into the atmosphere. Equipment: machinery and tools used to produce or process goods. Hazardous equipment that is improperly guarded and places workers in a danger zone around moving parts could cause injury or death. Lack-of a preventive maintenance program will make it difficult to ensure equipment operates properly. If there is no corrective maintenance program, then equipment that is broken or causing a safety hazard may not be fixed immediately and cause workers harm. Tools that are not in good working order, improperly repaired, or not used for their intended purpose only is an accident waiting to happen. Any maintenance person will tell you that an accident can easily occur if tools are not used correctly. Tools that are used while broken are also very dangerous. Environment: the general area that employees are working in. Poor facility design, hazardous atmospheres, temperature and/or noise can cause stress. If areas in your workplace are too hot, cold, dusty, dirty, messy or wet, then measures should be taken to minimize the adverse conditions. Extreme noise that can damage hearing should not be present. Workstations may be designed improperly (short people working at workstations designed for tall people), contributing to an unsafe environment. People: employees, management and others in the workplace. Copyright 2017 Geigle Safety Group, Inc. Page 11 of 75

20 Unsafe employee behaviors include taking short cuts or not using personal protective equipment. Employees who are working while fatigued, under of influences of drugs or alcohol, distracted for any reason, or in a hurry cause walking and working hazards. System: the processes and rules put into place to manage safety, also known as the safety management system. Management may unintentionally promote unsafe behaviors. Ineffective policies, procedures, rules (written and unwritten), practices and plans (also known as Administrative Controls ) that ignore safe behaviors or direct unsafe work practices ultimately represent the causes for about 98% of all workplace accidents. Supervisor Role As a supervisor, you have some tools that will help you identify and correct hazards in the five MEEPS areas discussed above. The Walk-around Safety Inspection One important activity to ensure a safe work area is to conduct an effective walk-around safety inspection. If your organization relies solely on the safety committee to identify workplace hazards, it's possible the process may be ineffective. The job of maintaining a safe and healthful work area is a primary OSHA-mandated employer responsibility, so, to be most effective, it makes sense that the safety inspection responsibility be delegated to the supervisor. Who is better positioned to effectively identify and correct workplace hazards than the supervisor? Remember, as an agent of the employer, the basic responsibility to inspect the work area may rest with the supervisor. As you conduct the inspection, you should be looking at the hazards associated with the five MEEPS categories discussed earlier (materials, equipment, environment, people and systems). In some instances, using an inspection checklist may be a good idea to make sure a systematic procedure is used. The only downside that can surface from using a checklist regards the "tunnel vision" syndrome: hazards not addressed on the checklist may be overlooked. Copyright 2017 Geigle Safety Group, Inc. Page 12 of 75

21 The Person Conducting the Inspections Most companies conduct safety inspections in compliance with OSHA rule requirements. But, is that good enough? Safety inspections may be effective, but only if those conducting the inspection are properly educated and trained in hazard identification and control concepts and principles specific to your company. It takes more to keep the workplace safe from hazards in industries that see change on a daily basis. Employees should inspect the materials, equipment, and tools they use, and their immediate workstation for hazardous conditions at the start of each workday. They should inspect equipment such as forklifts, trucks, and other vehicles before using them at the start of each shift. It's better to inspect closely and often and give the process enough time. One of the major weaknesses in the inspection process is that we just don't spend enough time in particular areas to detect all hazards. Again, we do the "rolling eyeball" as we walk through an area. How to Build an Effective Safety Inspection Checklist Step One: Determine the work area to be inspected, and the type of work being accomplished. Step Two: Talk with the safety director, workers' compensation insurer, or OSHA consultant to determine what safety rules apply to the work area. Obtain copies of the rules. Step Three: Select the rules that you feel directly apply to your work area. Many rules may not have significant impact on the work area you are responsible for. Step Four: Change each selected rule into a checklist question. Be sure to state the question as concisely as possible. Step Five: Ask employees who work in the area for recommended checklist questions. The result of following these procedures is a checklist that closely mirrors those hazards that OSHA will be inspecting. It might be a good idea to use an expert resource, such as those listed in Step Two, to evaluate the checklist you have developed. Make Everyone an Inspector As a supervisor, you probably don't want to be the only person inspecting for safety in your work area. You can, of course, delegate that responsibility to your workers. But how do you get them to willingly inspect for safety every day? Simple, (that's right, it doesn't have to be Copyright 2017 Geigle Safety Group, Inc. Page 13 of 75

22 difficult) you set the example yourself by inspecting regularly, you insist that they inspect, and you recognize (thank) your workers for inspecting and reporting hazards. The Job Hazard Analysis (JHA) Another effective activity to ensure a safe and healthful workplace is the Job Hazard Analysis (JHA). In the JHA process, you and your employee together analyze each step of a particular task and come up with ways to make it safer. The JHA goes far beyond the walk around inspection in its ability to eliminate or reduce most causes for accidents in the workplace. Why the JHA? The problem: Unfortunately, the walk around inspection is usually just an assessment. It merely attempts to determine if a hazard is present or not. It's conducted by one or two persons who walk around looking high and low to uncover hazardous conditions (I call this the "rolling eyeball syndrome"). If properly trained, they may effectively uncover hazards. If properly trained they may know how to effectively question employees during the inspection (they ask questions other than "any safety complaints?"). I think the most serious weakness inherent in the safety inspection process is that very little time is devoted to analyzing any one particular work area. The fix: The Job Hazard Analysis is not plagued with all these problems. It goes beyond mere assessment by truly analyzing the conditions and practices related to one specific task. When completing a JHA, you must: 1. Break the job task down into specific steps. 2. Analyze each step to uncover hazardous conditions and unsafe work practices. 3. Develop strategies to correct hazardous conditions and unsafe work practices. 4. Develop safe work practices for each step when hazards and practices can't be eliminated. 5. Develop safe and efficient work procedures for the entire job. Take a look at a simple JHA worksheet that you can adapt for your workplace. The chief advantage is that adequate time is given to analysis of both hazardous conditions and unsafe work practices. Consequently, it may be possible to eliminate or reduce all of the causes Copyright 2017 Geigle Safety Group, Inc. Page 14 of 75

23 for a potential accident. This advantage makes the JHA far more useful and beneficial in preventing accidents in the workplace. Although the occupational safety and health rules do not specifically require JHA's be accomplished on all hazardous tasks, we strongly recommend a formal JHA program conducted jointly by supervisors and employees. It makes good business sense. Investigating Incidents and Accidents Both the safety inspection and the JHA can be quite effective proactive safety processes to identify hazardous conditions and unsafe behaviors in the workplace. Although incident/accident investigations are "reactive" processes because they occur after the fact (the near-miss or injury) they may still be quite effective by identifying hazards and preventing future injuries. Check out the video to the right to learn more about the "Action Steps" in the incident/accident investigation process. Make sure employees report near-misses. It's a proven fact that investigating near-miss incidents is effective for a number of reasons. Investigating incidents is always less expensive than investigating accidents. They have to be, because an injury or illness has not occurred. Even a minor incident is important to investigate because, what might be today's cut finger, could be tomorrow's amputated finger. It's that simple. Accident investigation - Safety triage Accident investigations that occur after someone is injured remain very important to your company's safety and health management system if the primary purpose is to uncover root causes. If accident investigations occur only to place blame, they are basically a waste of time and will harm the safety management system in the long term. The Incident/Accident Investigation Process Accident investigation is a seven-step process with the ultimate for conducting accident investigations. 6. Secure the scene - to make sure evidence is not moved or disappears. 7. Document the scene - to gather data about the scene. Copyright 2017 Geigle Safety Group, Inc. Page 15 of 75

24 8. Conduct interviews - to determine events that led up to and included the accident event. 9. Develop the sequence of events - to determine exactly what happened in the proper sequence. 10. Conduct cause analysis - to determine surface and root causes associated with each event. 11. Determine the solutions - to develop immediate corrective actions and long-term system fixes. 12. Write the report - that emphasizes events, causes, solutions, costs, and benefits. Get To The Root Causes When conducting an incident/accident investigation, it critical to uncover the underlying root causes for the event. An incident or accident may be the result of many factors that have interacted in some dynamic way. When conducting an incident/accident investigation, be sure to include each of the following levels of analysis to make sure you uncover the root causes: Injury analysis - How did the injury occur? At this level of analysis, we focus on trying to determine the direct cause of the injury that may or did occur. Examples of the direct causes of injury include: Strain due to lifting heavy objects Concussion from impact forces due to a fall Tissue damage from contact with by a toxic chemical Burns from exposure to flammable materials Surface Cause Analysis - Why did the accident occur? Here you determine the unique hazardous conditions and unsafe behaviors that interact to produce the accident. Each of the hazardous conditions and unsafe behaviors uncovered are the surface causes for the accident. They give clues that point to possible root causes/system weaknesses. Examples of surface causes include: a broken ladder Copyright 2017 Geigle Safety Group, Inc. Page 16 of 75

25 a worker removes a machine guard a supervisor fails to conduct a safety inspection a defective tool Root cause analysis - Why did the surface causes occur? At this level, you're analyzing the weaknesses in the safety management system that contributed to the accident such as missing or inadequate safety policies, programs, plans, processes, or procedures. This level of investigation is also called "common cause" analysis (in quality terms) because you're identifying a system component that may contribute to common conditions and behaviors that exist or occur throughout the company. Examples of root causes include: lack of a safety training program inadequate or missing safety procedures lack of enforcement of safety violations failure to conduct safety inspections Scenario Trent, a new employee in the maintenance department, was told to remove a jammed conveyor belt. At the conveyor belt, he discovered that a wad of plastic had become tangled in a belt. As soon as he removed the plastic, the conveyor started up. Unfortunately, Trent's hand got caught in an incoming nip point and was severely injured. It might be relatively easy to determine what the surface causes for the accident in this scenario are, but what might be the most likely root cause(s)? Root causes are the missing or inadequate programs, policies, plans, processes or procedures that produced the hazardous conditions and unsafe behaviors described in the scenario above. Identifying hazards in your area of responsibility before they injure someone defines "adequate" supervision and sends a message of commitment and tough-caring leadership to your employees. I'm sure you'll realize many long-term benefits as a result of effective hazard identification. Copyright 2017 Geigle Safety Group, Inc. Page 17 of 75

26 Module 2 Quiz Use this quiz to self-check your understanding of the module content. You can also go online and take this quiz within the module. The online quiz provides the correct answer once submitted. 1. According to the Bureau of Labor Statistics, how many fatalities occur in the workplace each day? a. 25 b. 17 c. 3 d List the five general hazard categories. a. Materials, equipment, people, behaviors, procedures b. People, conditions, practices, performance, environment c. Materials, equipment, environment, people, system d. People, materials, behaviors, management, situations 3. The inspection program is more likely to be ineffective if. a. inspections teams are composed of employees and managers b. inspections are conducted only by safety committees c. inspections include employee interviews d. inspection frequency is proportionate to the degree of risk 4. The most serious weakness inherent in the inspection process may be that. a. inspections do not include employee interviews b. inspections are not proportionate to the degree of risk c. inspections are not conducted often enough d. little time is given to analyzing a particular work area Copyright 2017 Geigle Safety Group, Inc. Page 18 of 75

27 5. The accident investigation may be considered reactive. a. if its purpose is to fix the blame b. because the process occurs after an injury occurs c. if it fails to fix system weaknesses d. if any of the above exist or occur Copyright 2017 Geigle Safety Group, Inc. Page 19 of 75

28 Module 3: Correcting Hazards Introduction In the last module, we examined the inspection and JHA processes to identify hazardous conditions and unsafe behaviors in the workplace. Once hazards have been identified, it's important that they be corrected immediately or as soon as possible. Once hazardous conditions or unsafe behaviors are identified, it's important that the supervisor makes sure they are eliminated or reduced as soon as possible. To do this, one or a combination of the control strategies within the "Hierarchy of Controls" should be used. In this module, we'll take a look at the Hierarchy of Controls and how they can effectively correct identified hazards. For more information on improving the safety management system, see Courses 704, Hazard Identification and Control and Course 716, Safety Management System Analysis. The Hierarchy of Hazard Control Strategies Controlling hazards and exposures are the two basic strategies for protecting workers. Controlling hazards are more effective than controlling behaviors, and for good reason. If you can eliminate the hazard, you don't have to worry about exposure due to human behavior. Traditionally, a "Hierarchy of Controls" has been used as template for implementing feasible and effective controls. ANSI Z , Occupational Health and Safety Management Systems, encourages employers to employ the following hierarchy of hazard controls: Controlling Hazards 1. Elimination. "Design out" hazards and hazardous exposures. 2. Substitution. Substitute less-hazardous materials, processes, operations, or equipment. 3. Engineering controls. Isolate process or equipment or contain the hazard. Copyright 2017 Geigle Safety Group, Inc. Page 20 of 75

29 Controlling Behaviors 4. Administrative/work practice controls. Job rotation, work scheduling, training, welldesigned work methods, and organization are examples. 5. Personal protective equipment. Includes but is not limited to safety glasses for eye protection; ear plugs for hearing protection; clothing such as safety shoes, gloves, and overalls; face shields for welders; fall harnesses; and respirators to prevent inhalation of hazardous substances. As you can see, the control strategies first try to control hazards through elimination, substitution, or engineering. If the hazards can't be eliminated, replaced, or engineered, the hierarchy next attempts to control exposure to hazards through administrative methods and personal protective equipment. It's important to understand that: Elimination, substitution, and engineering controls are independent: they do not rely on behavior to be effective. Administrative, work practice, and PPE controls are dependent: they rely on compliant human behavior to be effective. The "big idea" behind this hierarchy is that the control methods at the top of the list are potentially more effective and protective than those at the bottom. Following the hierarchy of controls leads to the implementation of inherently safer workplace environments, where the risk of illness or injury has been substantially reduced. Now, let's take a closer look at the hierarchy of control strategies. Elimination Totally eliminating hazards, while most effective at reducing exposure to hazards, also tends to be the most difficult to implement in an existing process. This approach involves the initial design or redesign of tools, equipment, systems, production processes, and facilities in order to eliminate hazards associated with work. If the machinery, equipment, or process is still at the design or development stage, eliminating hazards may be inexpensive and simple to implement. However, for an existing process, major changes be that can be very expensive. In the long term, even expensive changes that eliminate serious hazards may be cost effective. Copyright 2017 Geigle Safety Group, Inc. Page 21 of 75

30 Examples of elimination controls include: Remove hazard from work zone, e.g., with exhaust ventilation to remove hazardous atmosphere. Signs, labels, alarms, and flashing lights give warnings. This is only successful if workers comply with the warnings. Two-hand controls, safety switches, and hand guards to prevent "caught-in" and other accidents. Ergonomically-designed tools to prevent cumulative trauma and other disorders. Use of laser and enclosure to reduce excessive noise. Replace the use of ladders with extension poles to change ceiling light bulbs to eliminate fall hazards. Substitution Substitution also focuses on doing something with the hazard, itself. It is simply replacing hazardous materials, processes, operations, machinery, and equipment with those that are less hazardous to reduce the severity of exposure. If you can't eliminate the hazard, then your thought should be, "how can I substitute this hazard with something less hazardous?" Examples: Replacing defective tools, equipment, machinery. Replacing a toxic chemical with a less/non toxic chemical. Replacing hazardous materials such as abrasives. Replacing hazardous chemicals, materials, tools, equipment or machinery may be expensive, but not as expensive as the average direct and indirect costs of a lost work time injury. According to the National Safety Council, is $34,000 and over $1 million to close a fatality claim. Engineering Controls Engineering controls use Prevention through Design (PtD) methods to prevent injuries and illnesses by "designing out" the hazards and risks. This approach involves the design or redesign Copyright 2017 Geigle Safety Group, Inc. Page 22 of 75

31 of tools, equipment, systems, work processes, and facilities in order to reduce or eliminate the hazards associated with work. PtD considers what is needed to protect workers throughout the life cycle process, machinery or and/ or process is being designed. The life cycle starts with concept development, and includes design, construction or manufacturing, operations, maintenance, and eventual disposal of whatever is being designed, which could be a facility, a material, or a piece of equipment. It s worth saying again: well-designed engineering controls are highly effective in protecting workers and will typically be independent of worker interactions to provide this high level of protection: no matter what workers do, they won't be exposed to hazards. Examples of effective engineering controls include: remove hazard from work zone, e.g., with exhaust ventilation two-hand to operate machinery use warning devices that stop operation if there is entry into hazard zone safety switches, hand guards, barriers, and machine guards redesign workstations and tools to best accommodate all workers ergonomically-designed tools automate processes to reduce worker exposure to repetitious movements use of laser and enclosure to reduce excessive noise enclosing a noisy machine presence-sensing devices place machine guards on a conveyor belt use a mobile scaffold Copyright 2017 Geigle Safety Group, Inc. Page 23 of 75

32 use a laser cutting machine to cut down on noise ergonomically-designed tools and equipment When considering engineering controls, you should think about the feasibility, costs, and ease of implementation of replacing or redesigning the equipment. OSHA expects your employer to consider these first three control strategies before employing administrative controls or personal protective equipment (PPE). Administrative Controls When exposure to the risk is not, or cannot, be minimized by other means, you should introduce administrative and work practice controls to reduce the risk. Administrative controls address how the work is structured, and direct people to work in a safe manner. They help establish effective processes and procedures in the workplace that reduce risk of injury and illness. A few examples include: limiting the amount of time someone is exposed to hazards written operating procedures safety and health policies, rules, and guidelines for employees alarms, signs, and labels use of the "Buddy system," especially in hazardous operations training on safe work practices and procedures requiring two or more workers to lift heavy loads worker rotation to minimize the duration of exertion, repetitive motions, and awkward/uncomfortable positions. written operating procedures, work permits, and safe work practices procedures that ensure workers are using and maintaining pneumatic and power tools properly Copyright 2017 Geigle Safety Group, Inc. Page 24 of 75

33 Work practice controls. These controls also focus on the way workers do their jobs to reduce exposure to hazards. Work practice controls help to limit exposure by decreasing the following factors: the frequency of exposure to the hazard, the duration of the task that exposes the employee to the hazard, and the number of employees exposed to the hazard. Preventive Maintenance. The best way to prevent breakdowns or failures is to monitor and maintain your equipment regularly. Determine what hazards could occur if your equipment is not maintained properly and plan to detect failures before they occur. Administrative and work practice controls used as the primary controls for protecting workers have also proven to be less effective than elimination, substitution, and engineering because the focus is on controlling employee behaviors rather than hazards. An important principle to remember is that "any system that relies on behavior is inherently unreliable." Personal Protective Equipment (PPE) Personal protective equipment is equipment worn to minimize exposure to hazards that cause serious workplace injuries and illnesses. These injuries and illnesses may result from contact with chemical, radiological, physical, electrical, mechanical, or other workplace hazards. Personal protective equipment may include items such as gloves, safety glasses and shoes, earplugs or muffs, hard hats, respirators, or coveralls, vests and full body suits. When engineering, work practice, and administrative controls are not feasible or do not provide sufficient protection, employers must provide personal protective equipment to their workers and ensure its proper use. PPE should be used in conjunction with, not instead of, the other hazard control strategies. A common mistake some managers and supervisors make is that they try to save a little money when purchasing PPE. Do not skimp on quality PPE: it can save a life. Employers are also required to train each worker required to use personal protective equipment to know: why it is necessary when it is necessary Copyright 2017 Geigle Safety Group, Inc. Page 25 of 75

34 what kind is necessary how to properly put it on, adjust, wear and take it off limitations of the equipment proper care, maintenance, useful life, and disposal of the equipment If PPE is to be used, a PPE program should be implemented. This program should address the hazards present; the selection, maintenance, and use of PPE; the training of employees; and monitoring of the program to ensure its ongoing effectiveness. Copyright 2017 Geigle Safety Group, Inc. Page 26 of 75

35 Module 3 Quiz Use this quiz to self-check your understanding of the module content. You can also go online and take this quiz within the module. The online quiz provides the correct answer once submitted. 1. Hazard control strategies attempt to eliminate or reduce. a. probability of severity and severity of a near miss b. exposure to hazards and probability of severity c. unsafe behaviors and poor performance d. hazards and exposure to hazards 2. Which hazard control strategy is most effective in protecting employees? a. Elimination b. Engineering Controls c. Personal Protective Equipment d. Administrative Controls 3. Which of the following hierarchy of controls uses solutions that are independent of human behavior? a. Work Practice Controls b. Engineering Controls c. Personal Protective Equipment d. Administrative Controls 4. Which Hierarchy of Controls strategy addresses how work is to be performed? a. Elimination b. Engineering Controls c. Personal Protective Equipment d. Administrative Controls Copyright 2017 Geigle Safety Group, Inc. Page 27 of 75